Good Faith Effort Documentation for CMS Network Adequacy
When you can't meet a CMS time-distance standard, good faith effort documentation is what stands between you and a deficiency. Here's exactly what CMS expects, how to build the audit trail, and what weak documentation looks like.
Good faith effort isn't a checklist — it's a documented story.
CMS does not define "good faith effort" with a specific number of calls or emails in regulation. What CMS reviewers evaluate is whether your documentation tells a credible, complete story of genuine attempts to recruit the provider — and a plausible explanation for why those attempts failed.
What CMS wants to see
- Multiple contact attempts across channels
- Documented dates and contacts
- Specific declination reasons (not just 'declined')
- Alternative access plan for members
- Attestation from a plan officer
What gets exceptions denied
- Single-attempt outreach
- Undated or reconstructed logs
- Missing declination reasons
- No alternative access plan
- Gap between outreach and filing
What triggers CMS scrutiny
- Same county + specialty gapped 2+ years
- High exception rate relative to service area
- Exception filings without audit trails
- Declination reasons that look templated
- Outreach attempts clustered in final 2 weeks
Four documented attempts. Six weeks minimum. Two channels.
The industry standard for a defensible good faith effort package — based on CMS audit findings and appeals outcomes — is four outreach attempts across at least two contact channels (written + phone) over a period of six or more weeks. Each attempt must be independently logged at the time it occurs.
Send a written invitation to participate, describing the plan, the LOB, the service area counties, and the reimbursement approach. Document the date sent and the recipient.
Call the practice's administrative contact. If you reach voicemail, leave a documented message. Log the call date, time, who you spoke with or that you left a message, and what was said.
Send a second written follow-up referencing your prior outreach. Note the filing deadline and the importance of timely response. This is the last written attempt before escalation.
Make a final call. If the provider declines, document the specific reason for declination. If no response, document the attempt and proceed to the exception filing package.
Documenting why providers declined — and how strong each reason is.
Not all declination reasons carry equal weight with CMS. A provider who says "not accepting new contracts" and signs a written declination is very different from a provider who simply never responded. Here's how to treat and document the most common scenarios.
| Declination Reason | Evidentiary Strength | Documentation Note |
|---|---|---|
| Not accepting new insurance contracts | Strong | Document with a dated written confirmation from the practice if possible. A verbal declination must be logged with the contact name and date. |
| Panel closed to new MA patients | Strong | Specific to Medicare Advantage panel status. Confirm whether the closure is plan-specific or MA-wide and document the response. |
| Rate dispute — CMS rates insufficient | Moderate | Document the rate offered and the provider's specific objection. Shows good faith rate negotiation occurred. |
| Administrative burden concerns | Moderate | Document the specific concern raised. Consider whether any process accommodation could resolve it; if not, document that too. |
| Not licensed in the service area counties | Strong | Verify and document licensure status as a factual reason for exclusion. |
| Practice closing or physician retiring | Strong | Document with any public confirmation available. Reduces provider supply permanently. |
| No response after 4 attempts | Acceptable | Four documented outreach attempts over 6+ weeks, with no response, constitutes documented good faith effort when accompanied by a signed attestation. |
Three exception pathways — only one requires full good faith documentation.
Access Exception
When used: When documented good-faith outreach has failed to secure adequate contracting
What CMS requires: Minimum 4 outreach attempts; documented declination reasons or non-response; alternative access plan (telehealth, adjacent county, referral arrangement)
Most common exception type; evaluated on quality of documentation, not just number of attempts
Geographic Exception (GEO)
When used: When a county has an objectively insufficient provider supply — typically HPSA-designated or frontier-classified counties
What CMS requires: HRSA HPSA or MUA designation documentation; evidence of all available providers in the county; alternative access plan
CMS often grants GEOs for frontier counties without requiring extensive outreach documentation when supply is demonstrably zero
Service Area Reduction (SAR)
When used: When a county cannot achieve adequacy and an exception is not viable
What CMS requires: CMS advance notification; member notification; state notification; timeline for implementation
Last resort — permanently removes the county from your service area for that benefit year
Blueprint builds the audit trail automatically.
Every outreach attempt logged in Blueprint's CRM becomes part of a timestamped, exportable audit record. When it's time to file an exception, Blueprint generates the good faith effort summary — showing every contact, every date, every outcome — ready to attach to your HPMS filing.
Timestamped outreach log
Every email, call, and follow-up logged with date, contact, and outcome
Declination reason capture
Structured fields for documenting why each provider declined
Exception summary export
One-click export of the good faith effort package per county and specialty
Adequacy gap visibility
See which counties need exception documentation before the deadline
Frequently Asked Questions
Related Resources